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Dr Craig Bowie
Special Counsel, Brisbane
I provide clients with front-end advice on a range of tax matters relating to business structuring, reorganisation and takeovers. My practice includes resolving taxation disputes for my clients, often by introducing novel arguments that allow us to reframe the issues and devise a successful resolution.
Through involvement in numerous tax community committees and memberships, I bring my clients new and innovative perspectives based on the latest thinking. 

My interest in energy, resources and climate change is complemented by the PhD I have recently completed in nuclear fusion research.

Career highlights

  • A multinational mining company – advised on the Australian tax implications of a $2.5 billion debt assignment, including commercial debt forgiveness, foreign exchange rules, limited recourse loan provisions, stamp duty and taxation of financial arrangements
  • Coal industry bodies and others – advised on various aspects of the research and development (R&D) tax incentive, including obtaining class rulings on mining company contributors’ ability to access the incentive for low-emissions technologies research, development and demonstration
  • A US-based client – provided guidance in relation to debt and equity rules, amendments to capital allowances rules, thin capitalisation rules and stamp duty. This included seeking a private ruling on debt, equity and capital allowances rules, which was the first private ruling to discuss the meaning of the term ‘financing arrangement’
  • A multinational mining company – successfully resolved a $20 million stamp duty dispute in relation to corporate reconstruction relief, which included developing a novel argument that was accepted by the Office of State Revenue
  • A Queensland liquefied natural gas company – helped with all aspects of compliance with the former carbon pricing mechanism. This included internal and external pass-through of carbon costs, and preparing submissions on drafting and amending the Clean Energy Act 2008 (Qld)
  • Advised on GST, stamp duty and income tax consequences of substantial infrastructure construction on State-owned land
  • Recognised by Doyles Guide as a leading tax lawyer in Queensland
  • Recommended by Best Lawyers for expertise in tax
  • Recently listed as a Rising Star nationally in the tax law category in The Legal 500 in 2020 and 2021. The Legal 500 said 'Brisbane-based special counsel Craig Bowie is a name to watch in the corporate tax space'...'Craig maintains a strong client base in the infrastructure, energy and resources and financial services industries.'

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